under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at depo

nder the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). This is evidenced through the intent of rule 26 disclosures. 6. As this court has recognized, Defendant sh